Tax Issues for Foreign Investors in Qualified Opportunity Zones: Deal Structures, Tax Rules, Planning Strategies

A live 90-minute premium CLE/CPE video webinar with interactive Q&A


Thursday, July 22, 2021

1:00pm-2:30pm EDT, 10:00am-11:30am PDT

Early Registration Discount Deadline, Friday, June 25, 2021

or call 1-800-926-7926

This CLE/CPE webinar will provide tax professionals guidance on tax challenges for non-U.S. investors in qualified opportunity zones (QOZs). The panel will discuss recent U.S. tax law developments and IRS regulations impacting foreign investors, legal requirements, and processes to achieve tax benefits. The panel will also provide insight on other critical tax considerations and planning strategies for foreign investors associated with opportunity zone funds and businesses.

Description

The 2017 tax reform created QOZs to encourage investment in specific geographic areas. Taxpayers investing in qualified opportunity funds (QOFs) can defer and even exclude the capital gain if they meet certain requirements.

To take advantage of the tax benefits of the QOZ program, a taxpayer must reinvest capital gain proceeds in a QOF within 180 days from the date of the sale or exchange of a capital asset. A QOF must hold at least 90 percent of the fund's assets in QOZ property. Tax counsel and advisers must understand and develop planning techniques to assist individuals or businesses seeking to invest capital, raise funds, or recognize significant capital gains in the next few years.

For foreign investors, the requirements and rules for investments in QOFs are particularly complex. On Apr. 12, 2021, the IRS proposed regulations on QOZs, providing new requirements and withholding relief for foreign investors in QOFs. The new regulations include requirements for eligible foreign persons and foreign-owned partnerships to acquire the federal income tax benefits under Section 1400Z-2 and reduce or eliminate withholding tax under Section 1445, 1446(a), or 1446(f) on certain transfers.

Listen as our panel discusses the necessary legal requirements and processes to achieve the tax benefits of QOZs, techniques to ensure deferral or reduction of capital gains for foreign investors, and recommended guidance for counsel and advisers.

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Outline

  1. Opportunity zone provisions under current tax law and recent IRS regulations
  2. Processes and criteria designating QOZs
  3. Key issues and planning for foreign investors
  4. Securing the tax benefits of opportunity zone investments
  5. Best practices and tax planning techniques for counsel

Benefits

The panel will review these and other key issues:

  • What are opportunity zones and eligibility requirements under IRC 45D(e)?
  • How can taxpayers ensure the deferral or reduction of capital gains and the appreciation exclusion?
  • What are the key provisions of recent IRS proposed regulations for foreign investors in QOFs?
  • What are the key issues impacting foreign investors and planning strategies to overcome them?
  • Optimizing structures for opportunity zone investments

Faculty

Lang, James
James O. Lang

Shareholder
Greenberg Traurig

Mr. Lang focuses his practice on tax credit incentive programs and related state and federal incentive programs. He...  |  Read More

Additional faculty
to be announced.
Attend on July 22

Early Discount (through 06/25/21)

See NASBA details.

Cannot Attend July 22?

Early Discount (through 06/25/21)

You may pre-order a recording to listen at your convenience. Recordings are available 48 hours after the webinar. CPE credit is not available on recordings. Strafford will process CLE credit for one person on each recording. All formats include program handouts.

To find out which recorded format will provide the best CLE option, select your state:

CLE On-Demand Video

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